PRIVACY NOTICE

This Privacy Notice describes how Native Markets, Inc. (“we”, “us”, “our”) collects, uses and discloses information about you when you use our website (nativemarkets.com), other Native Markets products or services, or otherwise interact with us, such as contacting support or using our services through a partner (collectively, the “Services”).

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not understand or agree to this Privacy Notice, please do not use or access the Services.

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we'll let you know. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

2. COLLECTION AND USE OF INFORMATION

We collect information in three ways: (1) what you provide to us, (2) what we collect automatically, and (3) what we get from other sources. In addition to the specific uses discussed below, we may use this information to provide and improve the Services and our product offerings, to maintain our business relationship, to enhance the safety and security of our Services, to detect and prevent fraud, provide customer support, conduct internal research and development, comply with applicable legal obligations, enforce any applicable terms of service, and protect the Services, our rights and the rights of our employees, users or other individuals.

Information You Provide to Us

Some features of the Services may require you to directly provide certain information, including information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit to us includes:

• Contact information, such as your name, address, email address, and phone number. We use this information to create and maintain your account and provide the Services, and to communicate with you.
• Account information, such as username, password, security questions that you select and the answers you provide, account handle and other information you add to your account or profile. We use this information to provide the Services, and to create, maintain and secure your account with us. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Supplemental identification information, such as your maiden name, tax ID, marital status, photograph, date of birth, gender and any other information contained in any identification documents you provide to us, such as a copy of your driver's license, passport, utility bills or proof of residence. We use this information to verify your identity and comply with legal obligations, including anti-money-laundering laws, and to detect and prevent fraudulent and other unauthorized activities.
• Financial and transaction-related information, such as your bank account number and associated details, your digital token wallet address, information regarding your transactions (including deposits and withdrawals) and your balance history. We use this information to provide you with the Services, enable you to transact with us, and to enhance your experience.
• Any other information you choose to provide us or otherwise include in communications with us, for example, when sending a message through the Services or calling our customer support team. We use this information to communicate with you or as otherwise notified to you at the time of collection.

Information Collected Automatically

We and third parties also automatically collect certain information about your interactions with the Services, including through cookies, pixels or other tracking technologies (“Tracking Technologies”). This information is collected and used to personalize the Services and tailor your experience, run analytics, and better understand user interactions with the Services. Such information includes:

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.
• Location information, such as approximate location based on IP address.
• Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data (e.g., page requests, page views, how much time is spent on a page, content viewed or interacted with, text entered, etc.), interactions with marketing emails, and ad impressions.

For further information on the use of Tracking Technologies, see the section below, Cookies and Other Tracking Technologies.

Information Collected From Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. We only use this information to help deliver our Services or verify your account. Such information includes:

• Information from the public blockchain, including timestamps of transactions or events, transaction IDs, transaction amounts and wallet addresses.
• Information from our business partners, with whom you may interact directly, including when you access our platform through a third party.
• Information when you choose to access the Services through a third party account, such as Google or Facebook, which we use to maintain your account and login information. These partners provide information such as your name, email address, and additional account information that is publicly available.

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices. For more information, see the section below, Third-Party Websites and Links.

Deidentified Information

Finally, we may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been deidentified/anonymized), and we may use such deidentified/anonymized information for any purpose.

TLDR: Why do we, when do we and what do we do with your data

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide you with the Services, comply with our legal and regulatory obligations (such as record-keeping requirements under anti-money laundering laws), resolve disputes, and enforce our agreements. When determining the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, and applicable legal requirements. When your information is no longer needed for these purposes, we will securely delete or anonymize it in accordance with our data retention policies.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES

As described above, we and third parties use Tracking Technologies to collect certain information about your interactions with the Services. Most browsers accept Tracking Technologies automatically, but you can usually change your settings to block or delete them. However, blocking or deleting cookies may cause some of the Services, including login features and general functionality, to work incorrectly.

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. You may also opt-out of the collection and use of information for interest-based advertising by advertisers that are part of certain industry alliances, including through tools offered by the National Advertising Initiative or the Digital Advertising Alliance, by clicking the links provided.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose your information for legitimate purposes subject to this Privacy Notice, including:

• Vendors or other service providers who help us provide the Services, including for identity verification, transaction monitoring, fraud detection and prevention, cloud storage, security, customer relationship management, marketing communications, analytics, payment networks, payment processing and the deployment of Tracking Technologies.
• Our affiliates or others within our corporate group.
• Business Partners, including those who you choose to access our platform or services through, where we need to disclose information in order to facilitate your access to our services. We also share your information with banking partners if you link a bank account, to enable us to process transactions that you initiate through the Services.
• Professional advisors, such as auditors, law firms, or accounting firms, including to assess, protect, enforce and defend our rights and to comply with our legal and regulatory obligations.
• Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction.
• For legal and security reasons and to protect our services and business, including to cooperate with law enforcement, judicial orders, and regulatory inquiries, to detect and prevent against fraudulent or illegal activity, to exercise or defend legal claims, and to ensure the safety and security of our business, employees, and users, and to enforce our terms or other agreements.
• With your consent or otherwise at your direction.

5. THIRD-PARTY WEBSITES AND MATERIALS

We may link to or integrate third-party websites and tools or show or make available content from them. Their privacy practices are their own, so please review their policies, notices and other terms before sharing information.

6. CHILDREN'S PRIVACY

Our Services aren't for children under 13, and we don't seek or knowingly collect information from children. If you think your child has shared information with us, contact us and we'll make commercially reasonable efforts to delete it.

7. DATA SECURITY

We use safeguards to protect your information, but no system is 100% secure. Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

We are based in the United States. If you are using the Services from outside the United States, please be aware that the information we collect from you may be transferred to, stored and processed in the United States or other countries outside your country of residence.

8. ADDITIONAL DISCLOSURES FOR U.S. STATE PRIVACY LAWS

This section applies to residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy laws, and supplements the information in this Privacy Notice.

Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information: identifiers (name, email, phone number, IP address, account name); financial information (bank account and routing number, bank address, transaction history, wallet address, beneficiary address, account owner name); internet or network activity (browsing history, interactions with our Services); and inferences drawn from the above.

Sources of Personal Information

We collect personal information from: you directly; automatically through your use of the Services; third-party sources such as identity verification providers, business partners, and public blockchains.

Purposes for Collection and Use

We collect and use personal information for the business and commercial purposes described in Section 2 of this Privacy Notice, including: providing the Services; verifying identity and preventing fraud; complying with legal obligations; improving our Services; and communicating with you.

Categories of Personal Information Disclosed for a Business Purpose

In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose: identifiers; financial information; commercial information; internet or network activity; and geolocation data. We disclose this information to service providers, business partners, and as otherwise described in Section 4 of this Privacy Notice.

Sale and Sharing of Personal Information

We do not sell your personal information for monetary consideration. We may share personal information with third-party advertising and analytics providers in ways that could constitute a “sale” or “sharing” under certain state privacy laws. You have the right to opt out of such sale or sharing.

Your Privacy Rights

Depending on your state of residence, you may have the following rights:

• Right to Know/Access: You may request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for collection, and the categories of third parties with whom we have shared it.
• Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to Opt Out of Sale/Sharing: You may opt out of the sale or sharing of your personal information for targeted advertising purposes.
• Right to Limit Use of Sensitive Personal Information: If applicable, you may limit our use of sensitive personal information to purposes necessary to provide the Services.
• Right to Data Portability: You may request a copy of your personal information in a portable, readily usable format.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

How to Exercise Your Rights

To submit a request, please email us at support@nativemarkets.com with the subject line “Privacy Rights Request.” We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf.

Right to Appeal

If we deny your request, you may appeal our decision by contacting us at support@nativemarkets.com with the subject line “Privacy Rights Appeal.” We will respond to your appeal in accordance with applicable law.

9. ADDITIONAL DISCLOSURES FOR USERS OUTSIDE THE UNITED STATES

If you are located in the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland, this section applies to you and supplements the information in this Privacy Notice.

Controller

Native Markets, Inc. is the controller of your personal data for purposes of applicable data protection laws.

Legal Bases for Processing

We process your personal data on the following legal bases:

• Performance of a Contract: Processing necessary to provide you with the Services and fulfill our contractual obligations to you.
• Compliance with Legal Obligations: Processing necessary to comply with applicable laws, including anti-money laundering and know-your-customer requirements.
• Legitimate Interests: Processing necessary for our legitimate interests, such as fraud prevention, security, improving our Services, and direct marketing, where those interests are not overridden by your rights and interests.
• Consent: Where you have provided consent for specific processing activities, such as marketing communications. You may withdraw consent at any time.

Your Data Subject Rights

Under applicable data protection laws, you have the following rights:

• Access: Request access to your personal data and information about how we process it.
• Rectification: Request correction of inaccurate or incomplete personal data.
• Erasure: Request deletion of your personal data in certain circumstances.
• Restriction: Request restriction of processing of your personal data in certain circumstances.
• Data Portability: Request a copy of your personal data in a structured, commonly used, machine-readable format.
• Object: Object to processing based on legitimate interests or for direct marketing purposes.
• Withdraw Consent: Withdraw consent at any time where processing is based on consent.
• Lodge a Complaint: Lodge a complaint with your local supervisory authority.

To exercise these rights, please contact us at support@nativemarkets.com.

International Transfers

Your personal data may be transferred to and processed in the United States and other countries outside the EEA, UK, or Switzerland. When we transfer personal data outside these regions, we implement safeguards.

10. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at support@nativemarkets.com